Paints and coatings are a priority category for ESPR due to VOC emissions and hazardous substance content. The delegated act is expected in 2027–2029. The DPP will require VOC content disclosure, biocide and heavy metal disclosure, recycled packaging content, and carbon footprint. Existing EU VOC limits under Directive 2004/42/CE remain in force under ESPR Article 74.
| Product Category | Maximum VOC (Water-Based) | Maximum VOC (Solvent-Based) | In Force Since |
|---|---|---|---|
| Interior walls and ceilings (matt) | 30 g/L | 400 g/L | 1 January 2010 |
| Interior walls and ceilings (sheen/gloss) | 100 g/L | 400 g/L | 1 January 2010 |
| Exterior walls (mineral substrate) | 40 g/L | 430 g/L | 1 January 2010 |
| Interior/exterior trim (gloss) | 100 g/L | 400 g/L | 1 January 2010 |
| Interior/exterior trim (matt) | 30 g/L | 400 g/L | 1 January 2010 |
| Interior woodwork (high gloss) | 130 g/L | 400 g/L | 1 January 2010 |
| Data Field | Annex III Category | Status |
|---|---|---|
| VOC content (g/L) | Substances of concern | Already required (Directive 2004/42/CE) |
| Biocide content (type and concentration) | Substances of concern | New under ESPR delegated act |
| Heavy metal content (Pb, Cr, Cd) | Substances of concern | New under ESPR delegated act |
| Isocyanate content (2K coatings) | Substances of concern | New under ESPR delegated act |
| SVHC substances above 0.1% w/w | Substances of concern | New under ESPR delegated act |
| Recycled packaging content | Recycled content | New under ESPR delegated act |
| Carbon footprint per litre | Carbon footprint | New under ESPR delegated act |
| End-of-life disposal instructions | End-of-life information | New under ESPR delegated act |
Paints and coatings are subject to the EU Paints Directive (Directive 2004/42/EC), which sets maximum limits for volatile organic compound (VOC) content. The ESPR paints and coatings delegated act will build on this foundation and add requirements for recycled content, substances of concern (particularly SVHC substances under REACH), carbon footprint, and the Digital Product Passport. The delegated act is expected to be adopted in 2027-2028.
| Data Category | Expected Data Fields | Basis |
|---|---|---|
| VOC content | VOC content (g/L), VOC category (Directive 2004/42/EC) | Existing (Directive 2004/42/EC) |
| Substances of concern | SVHC substances present, concentration, CAS number | REACH + ESPR Annex III |
| Recycled content | Recycled pigments %, recycled solvents % | New (ESPR Annex III) |
| Carbon footprint | CO2e per litre of product | New (ESPR Annex III) |
| Durability | Expected lifetime (years), coverage rate (m²/L), number of coats required | New (ESPR Annex III) |
| End-of-life | Waste classification, disposal instructions, recycling options | New (ESPR Annex III) |
Many traditional paint formulations contain substances of very high concern (SVHC) under REACH — including lead chromate pigments, cadmium pigments, and certain biocides. The ESPR paints DPP will require manufacturers to declare all SVHC substances present above 0.1% concentration. This will create transparency about the hazardous substance content of paints and coatings, enabling professional users and consumers to make informed choices about the products they use.
The ESPR delegated act for paints and coatings will require manufacturers to provide a Digital Product Passport that includes: product identifier and manufacturer details, VOC (volatile organic compound) content in grams per litre at the point of use, biocide content and active substances, substances of concern under REACH including any substances on the Authorisation List (Annex XIV) or Restriction List (Annex XVII), carbon footprint per litre of product, recycled content percentage where applicable, coverage rate in m² per litre at the specified dry film thickness, and end-of-life disposal instructions. For decorative paints, the DPP must also reference the product's classification under the EU Ecolabel criteria for indoor and outdoor paints (EU 2014/312/EU).
The EU Paints Directive (2004/42/EC) already sets VOC content limits for decorative paints and vehicle refinishing products. The ESPR delegated act for paints will build on these existing limits and extend them to industrial coatings and other product categories not currently covered by the Paints Directive. The ESPR will also introduce lifecycle-based requirements — not just VOC content at the point of application, but the full carbon footprint of the paint from raw material extraction through manufacturing, distribution, application, and end-of-life. Manufacturers of solvent-based paints and coatings face the greatest compliance challenge, as these products typically have higher VOC content and higher carbon footprints than water-based alternatives.
Many exterior paints and coatings contain biocides to prevent algae, mould, and fungal growth. These biocides are regulated under the EU Biocidal Products Regulation (BPR, EU 528/2012), which requires active substances to be approved before they can be used in biocidal products. The ESPR delegated act for paints will require manufacturers to disclose all biocide active substances in the DPP, referenced to their BPR approval status. Manufacturers using biocides that are under review or facing non-renewal under the BPR should begin reformulation work now to avoid a situation where their products become non-compliant under both BPR and ESPR simultaneously.
| Paint/Coating Category | Current VOC Limit (EU) | ESPR DPP Expected |
|---|---|---|
| Interior wall and ceiling paints (matt) | 30 g/L (Ecolabel) / 75 g/L (Directive) | 2027–2028 |
| Interior trim paints (gloss) | 150 g/L (Directive) | 2027–2028 |
| Exterior wall paints | 40 g/L (Ecolabel) / 75 g/L (Directive) | 2027–2028 |
| Industrial protective coatings | Not covered by Paints Directive | 2028–2029 (separate delegated act) |
| Vehicle refinishing products | 420–840 g/L (Directive, by category) | 2028–2029 |
The ESPR delegated act for paints and coatings is expected in 2027-2029, with a compliance date of 2029-2031. Paints and coatings are a priority category due to VOC emissions and hazardous substance content.
EU Directive 2004/42/CE sets maximum VOC content limits for decorative paints and varnishes. The limits vary by product category: interior wall paints (30 g/L for water-based, 400 g/L for solvent-based), exterior wall paints (40 g/L for water-based, 430 g/L for solvent-based). ESPR will add DPP requirements on top of these existing VOC limits.
The DPP is expected to require disclosure of: biocides (fungicides, algaecides); heavy metals (lead, chromium, cadmium); isocyanates (in two-component coatings); and any SVHC substances above 0.1% w/w.
The delegated act is expected to require disclosure of recycled content in paint packaging and may set minimum recycled content requirements for packaging. Recycled content in paint formulations themselves is limited by performance requirements.
VOC content is the amount of VOC in the paint product (measured in g/L). VOC emissions are the VOCs released during and after application. ESPR may require disclosure of both VOC content (already regulated) and VOC emission rates during application.
The EU DPP Registry goes live on 19 July 2026. EU customs will verify DPP compliance automatically from that date. Products without a valid DPP can be refused entry. Register now at Africa’s first ESPR-compliant DPP registry.
Register Your Digital Product Passport →Paints and coatings are a priority product category under ESPR because they contain a wide range of substances of concern — including volatile organic compounds (VOCs), biocides, heavy metals, and endocrine-disrupting chemicals — that can have significant impacts on human health and the environment. The EU has already restricted VOC emissions from decorative paints under Directive 2004/42/EC, but ESPR will go further by requiring manufacturers to disclose the full chemical composition of their products in the DPP and to meet minimum requirements for recycled content and recyclability.
The DPP for paints and coatings is expected to include: the product's VOC content (g/L); the product's carbon footprint per litre; the percentage of recycled content (recycled pigments, recycled solvents); information on substances of concern (biocides, heavy metals, endocrine disruptors, CMR substances); the product's spreading rate (m²/L); the product's expected durability (years); and instructions for safe disposal of unused product and empty containers. The DPP will enable market surveillance authorities, procurement officers, and consumers to compare the environmental performance of paints and coatings from different manufacturers.
The ESPR delegated act for paints and coatings is expected to be adopted in 2025–2027. Manufacturers should monitor the ESPR Working Plan for updates on the timeline. The existing VOC Directive (2004/42/EC) remains in force until superseded by the ESPR delegated act.
The scope of the ESPR delegated act for paints and coatings will be defined in the preparatory study. It is likely to cover decorative paints (for buildings and furniture) and may extend to industrial coatings (for vehicles, machinery, and infrastructure). The specific scope will be confirmed when the delegated act is published.
Biocides used in paints (such as isothiazolinones, which prevent mould and algae growth) are subject to the Biocidal Products Regulation (BPR). ESPR is expected to require disclosure of biocide content in the DPP and may restrict the use of biocides that are classified as substances of concern. Manufacturers should assess their biocide use and consider alternatives where possible.
Waterborne paints generally have lower VOC content than solvent-borne paints and are therefore better positioned for ESPR compliance. However, waterborne paints may contain other substances of concern (biocides, preservatives) that are subject to ESPR requirements. Manufacturers of both waterborne and solvent-borne paints must assess their products against the full range of ESPR requirements.
Yes. The DPP data carrier must be affixed to the product packaging (the paint tin or container). For small containers where space is limited, the QR code may be on the label. The DPP data must be accessible for the full lifecycle of the product, including after the container has been opened and partially used.